Security Policies and Procedures

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1 Security Policies and Procedures April 26, 2012 Kristen Whelan Transportation Consultant

2 Customs-Trade Partnership Against Terrorism What is C-TPAT? CBP and Industry Leaders working together to enhance national security and facilitate legitimate cargo. Strengthening the international supply chain through the exchange of ideas, knowledge, and best practices. C-TPAT is the largest government-private sector partnership to emerge from the terrorist attacks on September 11, C-TPAT was launched in November 2001 with seven major importers who also saw the need for the focus on supply chain security. The guiding principles for C-TPAT have been enhanced supply chain security, partnership, and a voluntary program.

3 What are the threats? Terrorism, sabotage Trafficking drugs; conventional, nuclear, chemical or biological weapons Illegal entry stowaways in containers, trailers Theft of cargo, personal property or information

4 Concealment Methods Money leaving US Drugs/WMD entering US

5 C-TPAT Benefits Securing the Homeland As part of contingency planning, C-TPAT partners will be the first to participate in the restoration of trade Reduced Examinations Front of line treatment Assigned Supply Chain Security Specialist Access to other programs (Free And Secure Trade (FAST), Importer Self Assessment (ISA), Simplified Entry, etc.) Supply Chain Security Conferences hosted by C-TPAT yearly Mutual Recognition e.g. EU

6 What are the added benefits of participating in C-TPAT? Companies that spend on supply chain security can expect an advantage far outweighing the costs of implementing security processes, according to a study by Stanford University. The study quantified some of the benefits of investing in security: Companies collectively reduced their Customs inspections by 48% Increased the automated handling of their imports by 43% Saw a 29% reduction in transit times Asset visibility in the supply chain improved by 50% 30% improvement in on-time shipping to their customers Reduced time taken to identify problems by 21% Reduced time taken for problem solving dropped by 31% Reduced inventory theft by 38% Excess inventory was reduced by 14% Reduced customer attrition by 26%

7 C-TPAT Security Criteria Security Criteria for importers Business Partner Requirements Documentation that they are a C-TPAT member Non-C-TPAT member, written or electronic confirmation or survey indicating they meet C-TPAT security criteria Container Security Written sealing procedures (PAS ISO seal) Seven-point inspection prior to loading / upon receipt Container Storage, secure locations, preventing of unauthorized entry into container or storage area Physical Access Controls Visitor procedures (including deliveries and mail) Logbooks, visitor badges, escorted access Employment Procedures Identification system

8 C-TPAT Security Criteria Personnel Security Procedures in place to screen prospective employees & to periodically check current personnel (Background & employment history) Personnel termination procedures in place to remove access Procedural Security Document processing accurate, complete & safeguarded Manifesting procedures accurate and timely Security Training and Awareness A threat and security awareness program established for all employees Employees must be made aware of the procedures the company has in place to address a situation and how to report it

9 Business Partner Requirements C-TPAT certification OR - Other security certification AND - Comply with C-TPAT importer security criteria AND complete survey and make visits to audit Applies to Suppliers who import raw materials, equipment, tooling used in production, etc. Suppliers who ship directly from overseas to Company locations worldwide Customs Brokers Freight Forwarders International carriers

10 Vendor Standards Credit worthiness - a cash poor company (individual) may be a desperate company (individual) How do documents arrive at your facility or your broker's facility? a sudden change in procedure by vendor must be questioned Who signs the docs? Sudden change in personnel should be questioned / reviewed for all vendors Who is training new personnel at your vendor site always ASK! Verify, Verify, Verify! Require proof of insurance

11 Container Security Container/trailer security Includes container/trailer seals Seals should be stored in a secure area ISO certified bolt seals only One or two people should handle seals Record & track each & every seal number used for shipments Location containers or trailers are stored Should be in an enclosed, secure area & trailer locations should be tracked Inspection prior to loading Use the 7-point inspection process Document the trailer inspection Shipper Load & Count Cargo be extra careful checking No one s looked at shipper load & count since the container was sealed at the factory Could be anything in that container

12 Cargo Security Recommendations Use CTPAT Certified Service Providers Use forwarders with web based tracking Check truck id's & container id s for all deliveries Deliveries by appointment only MAKE RANDOM UNANNOUNCED VISITS! Your cargo is as secure as the driver moving it Trucking is the trickiest point in cargo security Cargo at rest is cargo at risk keep cargo moving and avoid weekend moves Map your supply chain know where your cargo is at all times

13 Physical Access Controls Physical security Fencing Security Perimeter controls to keep unauthorized people from having access to your trailers or building Locks and alarms Keep unauthorized people out of secure areas If an emergency door is opened, an alarm should sound Cameras Show people arriving and leaving Show shipping and receiving areas Cargo handling and storage facilities must have physical barriers that guard against unauthorized access

14 Physical Access Controls ID s Physical access controls Employee identification and access Employees should wear their badges at all times Access to shipping and receiving areas should be limited to employees who need to be there Visitor identification All visitors must sign in and obtain a visitors badge Visitors should be escorted while in the building

15 Visitor Policy Key Take Aways How do you know someone is a visitor? What happens if you see an unescorted visitor? If something happens, how can I go back to my visitor log to figure out who was here? Care & control I know what s happening and who is in my building

16 Personnel Security Personnel Security Pre-employment screening On-going background checks Watching for suspicious behavior or activity

17 Procedural Security Document control Procedural Security Limited access to blank forms and completed document storage Shipping and receiving controls Discrepancy reports and follow-up Report threats and suspicious shipments Security training Information Technology Security Password protection Limit access to data storage areas Anti-virus software/ Firewalls IT security policies, procedures and standards must be in place and provided to employees in the form of training

18 Documentation Standards Look at type set - is it different anywhere in the doc? Use of white out or similar product? Wrong invoices are often used to clear goods cross check your documents to the PO If you can t check all documents, perform random checks Is document illegible or in a foreign language? Are documents missing? Why? Does weight on invoice match packing list, airwaybill and delivery order? Is piece count the same across all documents? DO NOT ACCEPT ANY DISCREPANCIES!

19 File & Documentation Protection Who has access to files? What leaves by way of hard or soft copy? Who keeps track of what's been "signed out" History files - purge them - ON TIME! Periodically audit - make sure nothing is missing

20 Cargo Marking & Document Protection Check marks & numbers against documents Change carton markings yearly Avoid use of company name & address on cargo Keep documents secure not w/cargo Shred all old documents Keep documents in a locked or secure area Computer system secure? Who has access to print a PO?

21 DC Security Have set receiving processes Check marks carefully Process must identify overages & shortages COUNT, COUNT & RECOUNT! Rigorously pursue all overages and shortages Segregate cargo that s not your own in a secure area Must check container numbers & seals against seal report / prealert from supplier Official stripping reports senior management audit against import documents Limit access to your facility Simple things like - restrooms for truck drivers Use simple common sense if something looks wrong, it probably is a problem

22 Courier & USPS Security Every package accounted for Who are they? Weak Link" - often ignored Insist on same standards Certify them

23 Become A Hard Target Take security seriously Maintain a low profile Layer your security Be Aware!

24 Reporting Suspicious Activity Post security rules where customers, employees and vendors can see them - DETERRENT Simple procedure for reporting irregular or illegal activity Incentive program for reporting suspicious activity

25 Change Is Good Randomness of activity enhances security Show up at unscheduled or unexpected hours Sudden shift changes in cargo loading area Unannounced audit of cargo loading area here & there Sudden shift changes in vendor payment area These are soft targets Rotate security on an unscheduled basis Unannounced visits to vendor sites

26 Continual Evolution Of Security Change= Hard Target Unexpected change makes thieves/terrorists look elsewhere Risk assessments of your vendors High risk countries meet higher standards Risk score for each vendor Random 3rd party spot checks Layered security Enforcement - what are the consequences?

27 How Criminals Circumvent Security Measures Loitering near the facility observing procedures, asking questions Taking pictures, obtaining plans or making diagrams of facilities Impersonating workers i.e. pest control Calling or ing employees about procedures

28 Recognizing Potential Security Risks Activity out of the norm Loitering out of normal sight lines Attempts to bypass security Clothing not suited to the weather Noises or odors not expected from containers Containers with holes, patches, missing or damaged seals or seal numbers that don t match Incorrect Hazmat labels for cargo Can you think of others?

29 Common Scams Last minute documents or deliveries Receipt or transaction under pressure Have a policy for receipt of cargo or documents in time for handling Have a policy for controlling last minute events Have a policy for notification of senior management when events occur SCAM SIGNAL: Is the person exceptionally nervous, rushed or angry without good reason?

30 Internal Conspiracy Here & There 80% of all theft in USA through internal conspiracy! Create and control separate receiving area 2 people verify each shipment Alternate roles frequently Shipping: one person assembles the order, one checks it, another loads the truck Minimizes theft AND errors

31 Preventing Internal Conspiracy Here & There Frequent inventories Close key control - key duplication Record of key use - termination policy Update / change security procedures at least once per year

32 Best Preventation Education & Awareness our employees & vendors know security is important! Educate employees Know our partners Create and share our security policy expectations Use C-TPAT certified service providers Implement a Security Policy and Procedures Secure our facilities, systems and conveyances Be conscious of security day to day

33 Securing the Supply Chain What can we/you do? Challenge unfamiliar or unidentified visitors in the office or warehouse Don t share system passwords Report in confidence any suspected or actual anomaly (irregularity) or illegal activity to management

34 Securing the Supply Chain What can we/you do? Report potential security risks to management i.e. broken lock, fence, security light, etc. Don t share information outside your company Be wary of outside requests for information about company policies, procedures, assets, etc.

35 Questions? Kristen Whelan, Liberty International (401) ext. 121

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